And they're off!

My client is a sole trader horse race bookmaker. He has traded as such since 1997. Some years ago the method of allocating pitches at horse racecourses either at the Tattersall's enclosure or the Silver Ring enclosure was changed and horserace bookmakers had the right to acquire such rights to stand within either of these enclosures on specific days within the racing calendar by bidding for such rights at auctions organised by the National Joint Pitch Council (NJPC). Some of these rights were acquired by my client at auctions held after 1 April 2002 the date of introduction of the intangible assets regime for corporates.

I incorporated my client's sole trade business with effect from 1 June 2007. The value of these racecourse betting pitches which he acquired has now been transferred into the company which is 100% owned by him.

My question arises as...